@Opus 17wrote:Also as mentioned, this is not actually part of the tax code or regulations. It's a general rule of thumb.
Six months as being "close in time" is not a general rule of thumb. It is, as I mentioned, individuals conflating the estate tax alternate valuation date rule set forth in Section 2032(a)(2) with the general rule.
In the case of property not distributed, sold, exchanged, or otherwise disposed of, within 6 months after the decedent’s death such property shall be valued as of the date 6 months after the decedent’s death.
The foregoing is only applicable if an estate tax return is required to be filed (Form 706).
@Opus 17wrote:I have not read any Tax Court cases or the audit manual to see what the IRS or the courts consider to be adequate proof.
Adequate proof is whatever the IRS determines in a particular case. Merely because the IRS accepted a CMA in one instance does not necessarily mean a CMA will be accepted in another. An appraisal by a certified appraiser is the prudent course of action, particularly if a substantial sum is involved.